CRCF Methodologies: collection of feedbacks from the "Have your say" ending on 19/02/2026

Business associations and businesses

• Copa-Cogeca, European Farmers European Agri-Cooperatives

"Copa-Cogeca strongly supports the overarching objective of establishing a credible and science-based certification framework capable of mobilising private finance for climate action in agriculture and forestry. In its current formulation, the cumulative interaction of conservativeness safeguards, financial additionality tests, long-term monitoring obligations and complex activity-planning requirements risks materially constraining participation. This would be contrary to the intention expressed in Recital 20 of Regulation (EU) 2024/3012, which emphasises the need for a credible revenue model capable of incentivising operators. We recommend clarifying eligibility pathways for underproductive land and ensuring that degraded sites with limited ecological value remain eligible where additionality and climate benefits are demonstrated. We also recommend clarifying that both organic and non-organic fertilisers are allowed where agronomically justified, provided associated emissions are accounted for in accordance with the methodology."

• European Biogas Association

"EBA supports the inclusion of the “use of organic soil improvers or organic fertilisers” among the practices that increase net carbon removals or reduce CO₂ emissions from soils. However, we urge that this term encompasses not only products certified under the EU Fertilising Products Regulation (Regulation (EU) 2019/1009) but also those approved under national legislation. EBA would like to recall that replacing synthetic fertilisers with organic alternatives contributes to reducing CO₂ emissions upstream by avoiding fossil gas-based fertiliser production. While the CRCF Carbon Farming methodology at stake in the current public consultation may not be the most suitable framework for accounting for these upstream emission reductions, these benefits must be recognised and captured under appropriate legislation."

• Grassroots Carbon, U.S. soil carbon company

"While we commend the methodologies proposed, we respectfully urge the Commission to broaden the framework's geographic scope to include carbon farming activities occurring in the United States, and to place a stronger emphasis on the massive global potential of regenerative grazing on pastures and grasslands. Including U.S. regenerative grazing projects in the EU certification framework is vital. Many of the corporations looking to purchase high-quality certified units are multinational companies based in or operating heavily within the EU. These companies have global agricultural supply chains that extend deep into U.S. agriculture. They must be able to invest in EU-certified soil carbon removals where they source their agricultural products."

NGOs

• Fern, an European NGO dedicated to protecting forests

"In line with a vast body of evidence confirmed yet again recently by peer-reviewed science, we do not think there is any merit in using carbon credits for funding carbon removal activities in the land sector. The issues at stake are simply intractable. While investments and ecosystem protection and restoration measures are urgently needed to make the land sector absorb more atmospheric CO2 and better resist the pressure of the climate and biodiversity crisis, carbon credits are simply not the way to do it, as it is too unlikely that this will achieve any benefit for forests and the climate. In fact, the opposite is true: carbon credits tend to oversimplify forest management at the expense of their other functions, and delay real climate action. Of course, the draft delegated act sets up a methodology for the certification of carbon farming activities and does not discuss the possible use cases for the certificates that would be produced, but it has been very clear from both the CRCF Regulation text and recent EU policy debates that the only use case considered is the certification of carbon credits."

• Climate Action Network Europe, Europe's largest NGO coalition fighting climate change (200 members)

"Given that land delivers multiple functions beyond carbon storage, including biodiversity protection, water regulation, soil health and food production, safeguards must ensure that carbon certification does not narrow land management objectives to a single CO2 metric. A harmonised and conservative accounting framework is necessary to ensure that certified activities deliver a genuine net climate benefit. If temporary practices are not incentivised to continue, the climate benefits generated during the crediting period risk being reversed. The CRCF Regulation emphasises that operators should be incentivised to prolong the monitoring period several times, to store captured carbon for at least several decades."

Academics

• Institute for Ecosystem Research, University of Kiel (Germany)

"Parts of the CRCF regulatory framework are not acceptable from scientific and practical perspectives. They will significantly hinder the implementation process of peatland projects. The duration of the activity period shall be at least 10 years, renewable up to a maximum overall activity period of 30 years. The limitation of the activity period is counterproductive for achieving climate protection goals associated with peatland landscapes for several ecological and economic reasons. It includes the fact that the implementation process of peatland restoration proceeds very slowly and, from a scientific perspective, it is highly uncertain whether peat formation will occur 30 years after rewetting. Additionally, the use of generalised emission factors (e.g., national EFs in the sense of Tier 2) is entirely inappropriate. This possible application stands in contrast to the previously required extremely high level of effort for auditing GHG emissions. From a scientific perspective, allowing such approaches would not be acceptable."

• Comité de rédaction de la méthode "Grandes Cultures" du Label Bas Carbone in collaboration with Agro-Transfert, Research Institutes in France

"Beyond eligible practices, it would be useful to indicate that crop diversification - where possible - is sought. As regards reduced tillage, the French scientific consensus does not recognise this practice as an additional factor for soil carbon storage, whether considered alone or combined with an increase in soil carbon returns. For the avoidance of doubt as to the meaning of the English term ‘soil improvers’, an explicit definition of what this means is necessary. Similarly, the concept of ‘precision fertilisation’ is worth clarifying. Establishing a sampling procedure to limit the uncertainties linked to the measurement of the soil organic carbon stock between two dates would also make sense to ensure the homogeneity of samples taken in the European Member State."

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